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ISSUE RESOLUTION MATRIX FOR FINDINGS AND KEY OBSERVATIONS

Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

1 ORAUTTKBS-0007-4 5 

Issue 1: (5.1.1.1) Routine Airborne Releases - 

Source terms provided require improvement for 

use in determining the worker intake from airborne 

releases at different INL facilities. The data 

NIOSH uses do not take into account the 

deficiencies in the environmental monitoring 

equipment and their locations, and, in addition, 

NIOSH does not assess the uncertainties 

associated with the meteorological dispersion 

model used for the INL site. Most importantly, the 

source terms do not account for worker inhalation 

of resuspended contaminated soils and materials 

around the INL facilities. 

45

The SC&A comments are directly 

related to the Tiger Team report 

(DOE/EN-0178, 1991). That 

report cites 40 CFR 50 and 40 

CFR 58, both of which are EPA 

regulations concerning primary 

ambient air quality standards. The 

equipment type, location 

requirements, and uncertainties 

referred to in those standards are 

designed for purposes other than 

what NIOSH is using this data. 

The dose calculations made by 

NIOSH are independent of the 

requirements in those standards. 

NIOSH requests the reference 

SC&A used to determine that the 

uncertainties not accounted for in 

the meteorological dispersion 

model. 

03/12/14 Update: As tasked 

during the 2011 INL Working 

Group meeting, NIOSH has 

revisited the meteorological 

dispersion model that was used to 

calculate the environmental 

intakes in ORAUT-TKBS-0007-4. 

The focus of that revisitation

involved investigating SC&A’s

concerns about the model not 

being appropriate for evaluating 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

dispersion coefficients at distances 

<20 km from the release point, and 

the source terms not accounting 

for worker inhalations of 

resuspended contaminated soils 

and materials. The results of that 

investigation have been provided 

to the INL working group in a 

white paper.

2 ORAUTTKBS-0007-4 6

Issue 2: (5.1.1.2) Episodic Airborne Release - The 

airborne releases associated with several of the 

Initial Engine Tests of the Aircraft Nuclear 

Propulsion (ANP) Program were likely to have 

been underestimated by factors ranging from 2 to 

16. Also, NIOSH did not evaluate the 

uncertainties associated with the deficiencies in air 

monitoring equipment.

55

Please provide a basis for the 

“factors ranging from 2 to 16.” 

Please see response to number 1 

regarding uncertainties.

03/12/14 Update: As tasked 

during the 2011 INL Working 

Group meeting, NIOSH has 

reviewed the SC&A report 

(Critical Review of Source Terms 

for Select Initial Engine Tests 

Associated with the Aircraft 

Nuclear Propulsion Program at 

INEL) on the Risk Assessment 

Corporation (RAC) modeling 

approach that was used for the 

INL site. The results of that 

review have been provided to the 

INL working group in a white 

paper.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

3 ORAUTTKBS-0007-4 7

Issue 3: (5.1.1.3) Direct Gamma Exposures – The 

fence-line TLD measurements are not adequate for 

reconstructing direct gamma doses to personnel 

working outdoors at and around a specific INL 

facility inside the fence-line boundary, because 

they do not take into account the most bounding 

scenarios. 

57

Personnel within the various 

facilities were monitored and 

access was controlled. Dosimetry 

was required to enter the various 

“fenced” facilities on site. TLDs 

were placed on the fences 

enclosing the various facilities. 

The dose from these TLDs 

represents the bounding condition

at the closest point an unmonitored 

individual could get to a facility. 

Closed

4 ORAUTTKBS-0007-5 8

Issue 4: (5.1.2.1) Completeness and Quality of 

INL Internal Dosimetry Programs - The 

identification and determination of missed internal 

dose for workers are heavily influenced by the 

assumption of confidence, but SC&A found this 

premise to be unsupported after examining several 

critical DOE-HQ Tiger Team and DNFSB site 

audit reports. In addition, many site experts 

interviewed by SC&A indicated that there were 

significant deficiencies and inconsistencies in 

radiation work practices throughout the operating 

history of the INL facilities. These observations 

jeopardize the validity of the TBD approaches in 

reconstructing missed worker internal doses. 

73

The default table for missed dose 

(5-24) does not have a basis in the 

“confidence” of the INL 

radiological program. The table is 

based on monitoring results, 

favorable ratios, and other 

claimant favorable assumptions. 

However, in resolving issue 

associated SC&A’s Finding 3.5-1, 

for the ANL-W Site Profile, the 

previous approaches used to 

calculate missed and unmonitored 

internal doses have been 

completely replaced. The missed 

and unmonitored doses for 

activation and fission products are 

now based on the approach 

described in OTIB-0054. The 

unmonitored actinide doses are 

now being calculated using a new 

site-specific approach based on 

source term information and a 

SC&A 

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

broader list of radionuclides.

5 ORAUTTKBS-0007-5 9

Issue 5: (5.1.2.2) High-Risk Jobs (Internal 

Exposure) - NIOSH did not evaluate 

comprehensively the facility and field data to 

identify and separate out the high-risk or high-dose 

jobs for worker internal exposures. This 

information is essential for dose reconstructors to 

fill in the data gap when dose records in a 

claimant’s file are not complete. 

77

NIOSH has monitoring records for 

internal dose and NIOSH feels the 

records are fairly comprehensive 

for “high-risk” jobs. The TBD 

contains requirements for 

reconstructing internal doses and 

for missed doses. 

SC&A 

recommends that 

this finding remain 

open for further 

discussion.

6 ORAUTTKBS-0007-5 O

Issue 6: (5.1.2.3) Calibration of Internal 

Dosimetry Analytical and Monitoring Equipment -

The TBD does not provide any information on the 

calibration procedures, sensitivities, and standards 

of the internal dosimetry analytical equipment and 

monitoring instrumentation. The 1991 DOE Tiger 

Team findings show the deficiencies in these 

areas. NIOSH should evaluate the uncertainties 

and impacts on the internal dose assessment results 

associated with the deficient calibration programs 

at INL.

78

The references cited in the TBD 

provide information on the 

analytical equipment maintenance. 

Other facility audits find the 

program adequate.

The equipment type, location 

requirements, and uncertainties 

referred to in the Tiger Team 

report are designed for purposes 

other than what NIOSH is using 

this data. The dose calculations 

made by NIOSH are independent 

of the issues discussed in an old 

Tiger Team report. NIOSH did 

account for uncertainties 

associated with the radiological 

model.

SC&A 

recommends that 

this finding remain 

open for further 

discussion.

7 ORAUTTKBS-0007-5 O

Issue 7: (5.1.2.4) Changes of Internal Dose Limits 

- Inconsistent work practices were prevalent in the 

early years of the INL operation and may have led 

to significant missed dose to workers. NIOSH 

should evaluate the impacts of these dose limit 

78

Dose limits have no impact on 

missed doses, since missed doses 

are solely the doses that would 

have gone undetected by a 

particular monitoring method 

Closed
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

changes over the operating history of INL to see 

whether there were missed doses in the early years 

when the radiation protection policy was less 

protective and inconsistently implemented. 

because of the limit of detection. 

Whereas, unmonitored dose is that 

for which no monitoring was 

performed. Therefore, NIOSH’s 

response assumed that this 

comment was applicable to the 

potential unmonitored doses, since 

the dose limits influenced when 

internal dose monitoring was 

performed. 

A review of 90,515 urine sample

results indicates that over 98% of 

the gross beta (GB) and gross 

gamma (GG) in urine results were 

below the MDA values provided 

in this TBD. In addition, a 

significant number of those 

positive bioassay measurements 

were follow-up measurements to 

previously identified intakes. 

Given that an overwhelming 

majority of the GB and GG in 

urine bioassay results, which 

constitutes most of the bioassay 

data in the early year of the INL’s 

operations, were below the MDAs 

for those measurement methods, it 

is unlikely that the alleged 

inconsistent practices led to 

significant unmonitored internal 

doses.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

8 ORAUTTKBS-0007-5 10

Issue 8: (5.1.2.5) High-Fired Plutonium and 

Uranium Intakes - The TBD did not evaluate the 

hazard associated with high-fired plutonium and 

uranium at the INTEC (ICPP) and RWMC 

facilities. High-fired Pu-238, Pu-239, and uranium 

are not easily dissolvable, nor do they readily 

break into very small particles. They also emit 

some gamma rays and neutrons. Similar to the 

treatment of recycled uranium, NIOSH should 

evaluate the lung dose for intake of high-fired 

uranium and plutonium oxide particulates 

(alveolar deposition). 

78

The INL internal TBD has been 

revised to include super-S Pu as a 

potential material type at the INL. 

Please define what you mean by 

high-fired uranium intakes.

SC&A 

recommends 

closing

9 ORAUTTKBS-0007-5 O

Issue 9: (5.1.2.6) Skin and Facial Contamination –

This TBD does not consider incidents with 

workers having skin contamination, facial 

contamination, and positive nasal swipes in the 

INL facilities. These kinds of problems would be 

compounded by the deficiencies in air sampling 

systems and ineffective respiratory protection 

programs. Guidance should be provided to a dose 

reconstructor to account for the missed dose due to 

the unaccounted uptake. 

79

All versions of the internal TBD 

have indicated that the monitoring 

and analytical programs were 

designed to initiate, through in 

vitro and/or in vivo bioassay 

analysis, an investigation of any 

potential internal intake as 

indicated by positive air sampling, 

personnel contamination, etc... 

As a result, the skin and facial 

contamination incidents would 

have follow-up in vitro and/or in 

vivo bioassay measurement data 

when an intake was suspected. 

Therefore, the alleged deficiencies 

are of no consequence in NIOSH’s 

dose reconstruction methods, since 

urine, fecal, whole body count, 

and lung count data would take 

precedence over air monitoring, 

contamination survey, and nasal 

smear data.

SC&A 

recommendation is 

pending a review 

of NIOSH’s 

response to its WG 

action item.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

03/12/14 Update: As tasked 

during the 2011 INL Working 

Group meeting, NIOSH has 

conducted additional research on 

INL practices to monitor and 

control skin contamination. The 

results of that investigation have 

been provided to the INL working 

group in a white paper.

10 ORAUTTKBS-0007-5 O

Issue 10: (5.1.2.7) Breathing Rates – The TBD 

assumption appears less claimant favorable than 

the ICRP or NCRP assumptions. 

79

Based on the Section 5.1.2.7 of 

SCA-TR-TASK1-0005, this 

comment is actually being made 

for ORAUT-TKBS-0007-4.

NIOSH was only able to find 

breathing rate information in 

Footnote c of Table 1 in ICRP 68, 

which also indicates that the 

information being provided was 

obtained from Table 6 of ICRP 

66. The breathing rates in ICRP 

Reports 23, 66, and 68 for 8 hr of 

light work activity are all 9.6 

m3

/workday. The INL 

Environmental TBD used an 

intake rate of 2,400 m3

/yr, which 

is equivalent to 9.6 m3

/workday 

times 250 workdays/yr. 

Therefore, the breathing rate used 

in the INL Environmental TBD is 

equivalent to the breathing rates 

recommended in ICRP Reports 23, 

66, and 68.

Closed
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

11 ORAUTTKBS-0007-5 11

Issue 11: (5.1.2.8) Non-Occupational Worker 

Elimination of DU Background – The derivation 

of the background value of 0.16 μg/L used for 

subtraction from each urinalysis result of uranium 

prior to assessment of occupational internal dose 

for SMC radiation workers is not technically 

sound. The baseline background (population) 

intake value was determined by a study of urine 

samples submitted by non-radiation workers at the 

SMC facility. A better approach would be to use 

the urine excretion samples by non-INL people in 

the Idaho Falls areas. NIOSH should consider this 

subtraction from urinalysis results as a missed 

internal dose. 

79

The idea to collect background

samples from non-INL personnel 

is not feasible and is unreasonable. 

ICRP 23, lists the daily intake of 

naturally occurring uranium as 1.9 

μg per day. Assuming 

equilibrium, the daily excretion of 

uranium through urine would also 

be 1.9μg. Applying the excretion 

volume for Reference Man of 1.4 

liters per day, this results in a 

range of typical urinary 

concentration of 0.04 to 0.5 μg/L. 

Therefore, the INL’s adjustment 

value of 0.16 μg/L is consistent 

with ICRP reference values for 

natural uranium. 

Reference:

King, V. A., 2001, Technical Basis 

for Internal Dosimetry at SMC, 

EDF No. SMC-2001-02, Rev. 3,

Idaho National Environmental and 

Engineering Laboratory, Idaho 

Falls, Idaho, May 31. [SRDB Ref 

ID: 8479, p. 67]

Closed

12 ORAUTTKBS-0007-5 O

Issue 12: (5.1.2.9) Unmonitored Workers - The 

potential missed doses for unmonitored workers 

would be from inhaling resuspended contaminated 

soils and ingesting contaminated materials while 

eating in a contaminated, previously considered 

uncontaminated, area (such as office and 

cafeteria). NIOSH should evaluate these potential 

missed doses. 

80

These scenarios are considered in 

the development of unmonitored 

doses.

Closed
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

13

ORAUTTKBS-0007-

4/5/6

O

Issue 13: (5.1.2.10) Naval Reactor Facility 

Workers - As the internal dose TBD indicates, 

“some workers’ internal dose could have resulted 

from their support work at the NRF.” NIOSH 

should evaluate the potential missed dose at the 

NRF for these workers. 

80

Workers assigned to the NRF are 

not covered as required by 

EEOICPA. However, doses 

received by NRF workers while 

responding to the Stationary LowPower Reactor Number One 

(SL-1) accident are covered.

Closed

14 ORAUTTKBS-0007-5 O

Issue 14: (5.1.2.11) Plutonium Monitoring - The 

TBD does not provide any historical information 

on the plutonium analysis methods used at INL. It 

is entirely possible that selective plutonium 

monitoring on workers was used at INL until 

1980, but without this information, the dose 

reconstructors would not be able to assign missed 

internal dose due to plutonium intakes in the time 

period before 1980. NIOSH should provide 

information on plutonium monitoring. 

80

Because plutonium was not 

separated from the spent nuclear 

fuel at the INL, the plutonium was 

always present with the more 

readily detectable mixed fission 

products that were also in the 

spent nuclear fuel. Therefore, in 

the vast majority of the plutonium 

exposure scenarios, the plutonium 

would have been present with the 

product and waste streams 

containing mixed fission products, 

and any intakes of radioactivity 

would have been more readily 

detectable by performing bioassay 

measurements for mixed fission 

products. Exceptions to these 

exposure scenarios may have 

included exposures to laboratory 

workers that may have separated 

and/or handled laboratory 

quantities of plutonium and the 

limited number of workers that 

may have somehow received a 

plutonium intake from the 

plutonium that was plated out on 

the surfaces inside a 

SC&A 

recommends

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

decontaminated hot cell at the 

ICPP. Performing bioassay 

measurements for these few types 

of scenarios and possibly just as 

experimental bioassay procedures, 

would explain the sporadic 

plutonium bioassay data. Because 

the INL appears to have routinely 

performed bioassay measurements 

for mixed fission products when it 

thought there was any potential for 

exposure, and because the intakes 

of mixed fission products can be 

correlated to intakes of plutonium, 

the dose reconstruction process for 

the INL involves assigning missed 

plutonium doses based on either 

Pu:Sr-90 or Pu:Cs-137 ratios that 

get applied to intakes that were 

estimated for those fission 

products.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

15

ORAUTTKBS-0007-

4/5/6

1

Issue 15: (5.1.3) SL-1 Accident Dose 

Reconstructions - The TBDs do not evaluate the 

potential missed internal and external doses or the 

associated uncertainties for the over 1,000 rescue 

and cleanup workers involved with the SL-1 

accident that occurred in January 1961. There was 

a high potential for significant exposures, because 

the equipment used and the radiological control 

policies in place in that era were not as advanced 

and protective as those in current use. The TBDs 

should develop adjustment factors related to stay 

time, dose field estimates, internal dose results, 

external dose readings, and contamination level 

estimates. 

80

NIOSH has a significant dosimetry 

history for first-responder and 

recovery workers at the SL-1 

facility. The dosimetric records 

provide enough data to accurately 

reconstruct doses. In some 

instances SL-1 specific coworker 

dose is used. SL-1 dose 

reconstruction data is addressed in 

the TBD.

SC&A 

recommends that 

this finding remain 

open for further 

discussion.

16 ORAUTTKBS-0007-6 8

Issue 16: (5.1.4.1.1) Completeness and Quality of 

INL Beta/Gamma Dosimetry and Record Keeping 

Programs - The identification and determination of 

missed external dose for workers are heavily 

influenced by this assumption of confidence, but 

SC&A found this premise to be unsupported after 

examining several critical DOE-HQ Tiger Team 

and DNFSB site audit reports. In addition, many 

site experts interviewed by SC&A indicated that 

there were significant deficiencies and 

inconsistencies in radiation work practices 

throughout the operating history of the INL 

facilities. These observations jeopardize the 

validity of the TBD approaches in reconstructing 

missed worker external doses. 

96

Please provide the reports of 

“significant deficiencies and 

inconsistencies in radiation work 

practices” and provide how the 

NIOSH-derived missed dose 

calculations are subject to the 

results of the Tiger Team report.

NIOSH has no plans to develop an 

external coworker dose model.

SC&A 

recommends that 

the WG keep this 

issue open pending 

receipt and review 

of the INL-specific 

coworker model.

17 ORAUTTKBS-0007-6 4

Issue 17: (5.1.4.1.2) Penetrating and NonPenetrating Doses - NIOSH should re-evaluate the 

missed gamma dose, due to the deficiencies in the 

procedures and algorithms. 

96

The under-reporting of the 

penetrating photon doses, due to 

the two-element film dosimeter’s 

limitation for measuring low 

energy photon doses, at the INL is 

SC&A 

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

much less of a significant situation 

for the majority of exposure 

scenarios than what is being 

indicated by SC&A. 

INL Health Physics personnel 

have been aware of the dosimeter 

response issues associated with 

low energy photons for many 

years, including at least some of 

the years when the two-element 

film dosimeters were being used. 

However, there were ways for the 

dosimetry personnel to determine 

whether a non-penetrating dose 

was likely attributable to beta or 

low energy photon radiation. One 

such way was noting the ratio of 

the OW and S readings from the 

dosimeter, since this ratio should 

be relatively consistent for similar 

radiation fields (i.e., in terms of 

radiation type and energy 

distribution). Because the OW 

reading for the two-element film 

dosimeters being used at the INL 

had a significant over-response to 

low-energy photons, an unusual 

amount of blackening on the OW 

film would be observed when the 

dosimeter was exposed to low 

energy photons. Therefore, an 

OW to S reading ratio that was 

significantly higher than usual 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

would be an indication that the 

worker’s non-penetrating dose 

contained a significant 

contribution from low-energy 

photon exposure. Also, using such 

dosimeter readings as is would 

potentially result in a significant 

overestimate of the nonpenetrating dose that was being 

reported and could potentially 

have resulted in a dose limit being 

exceeded. Therefore, it was in the 

INL’s best interest to at least be 

somewhat familiar with the OW to 

S reading ratios and the photon 

energy distributions for the various 

exposure scenarios and to adjust 

any doses that were too high 

because of the dosimeter’s overresponse to low energy photons. 

In addition to the unusual amount 

blackening that would have been 

observed on the OW dosimeter, 

the survey instrument readings 

would have indicated to the INL 

Health Physics personnel that the 

“beta” doses based on the 

dosimeter results were being 

significantly over-reported and 

that they were likely seeing the 

effect of the dosimeter’s overresponse to low energy photon 

radiation, since the hand held 

survey instruments that were 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

carried during most hot jobs did 

not over-respond to the low energy 

photons.

18 ORAUTTKBS-0007-6 O

Issue 18: (5.1.4.1.3) Correction For Beta Doses –

NIOSH should develop a method to consistently 

account for uncertainties in dosimetry readings. 

Claimant-favorable correction factors should be 

developed for beta dose reconstruction.

97

Table 6-9 in the TBD provides 

correction factors for underreporting. Comment 18 quotes the 

following statement along with

several others from OCAS-IG001, which are quotes from 

Revision 1 (OCAS 2002) versus 

Revision 3 (OCAS 2007) of the 

OCAS-IG-001 and some of which 

is no longer in OCAS-IG-001. “If 

individual energy distribution 

information is not available for 

two-element film badges, the open 

window dose should be used as a 

claimant friendly estimate of the 

30 to 250 keV dose.” However, 

the comment didn’t quote some 

statements that were in between 

the quoted statements. One such 

statement was, “When monitoring 

data do not indicate the relative 

energy distribution, the 

distribution can be estimated based 

upon either the site radionuclide 

inventory or the relative energy 

distribution which can be 

estimated for most facilities based 

upon a review of historical 

operations,” which is still a 

statement in Revision 3 of OCASIG-001 (OCAS 2007) and is what 

SC&A 

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

was used for the INL TBD. The 

photon energy distribution of 25% 

30–250 keV photons and 75% 

>250 keV photons in the INL TBD 

is claimant-favorable for the 

majority of exposure scenarios at 

the INL, based on the radioactivity 

in The Materials Test Reactor’s 

(MTR’s) spent reactor and the 

waste stream for the ICPP (see 

attached file). MicroShield 

calculations indicate that 88.9% of 

the photons in the spent MTR 

reactor fuel have an energy greater 

than 300 keV, and that percentage 

increases to 98.8% for the ICPP’s 

waste stream that contains all of 

the fission products and 

transuranics. It should also be 

noted that these energy 

distributions do not account for the 

effect from any minimal shielding 

that would have been in place for 

most exposure scenarios and 

would have further reduced the 

amount of low-energy photons that 

the workers were being exposed 

to.

In addition, the potential underreporting of the penetrating photon 

doses would have only been able 

to have occurred when the 

reported non-penetrating dose was 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

significantly greater than the 

dosimeter’s limit of detection, 

since the OW reading for the 

dosimeter would have been 

capable of detecting the lowenergy photons and would have 

significantly over-responded to 

them. Therefore, this issue is only 

potentially applicable to the 

instances when a significant nonpenetrating dose is reported for a 

specific dosimeter. Because 

reviews of the dosimetry data for a 

significant number of cases 

indicate that the majority of nonpenetrating doses reported for 

most INL workers were either zero 

or insignificant, NIOSH expects 

that the number of potentially 

under-reported penetrating photon 

doses would have been very small. 

If SC&A has encountered any 

specific examples where an INL 

worker’s penetrating dose was 

likely under-reported, NIOSH 

would be willing to investigate this 

potential issue further.

It should also be noted in 

Comment 18 that the reference to 

the correction factor used at the 

SRS (i.e., the factor of 1.119) is 

not applicable to other sites.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

19 ORAUTTKBS-0007-6 O

Issue 19: (5.1.4.1.4) Angular Dependence 

Correction Factor for Gamma Dose - NIOSH 

should provide angular dependence (anatomic 

geometry) correction factors for external gamma 

doses, particularly for low-photon energies, where 

the angular dependence of the sensitivity of the 

dosimeter is most pronounced. These correction 

factors are used to account for, for example, the 

bias introduced by a dosimeter worn at the neck 

level and the higher doses received by 

tissues/organs below the waist. 

99

Revised Response for WG 

Review: When appropriate, the 

Technical Information Bulletin: 

Best Estimate External Dose 

Reconstruction for Glovebox 

Workers (DCAS-TIB-0010) 

allows the dose reconstructors to 

apply a special geometry 

correction factor to the doses to 

organs in the lower torso to 

account for the angular 

dependence associated with 

working with radioactive materials 

in gloveboxes or other benchtop 

work environments (referred to as 

just glovebox work after this 

point) (DCAS 2010). The use of 

the approach described in DCASTIB-0010 to adjust the doses to the 

organs in the lower torso when 

glovebox work was performed has 

since been approved by the 

Procedures Subcommittee. Even 

though the external TBD does not 

refer to DCAS-TIB-0010, the 

external TBD does refer to 

External Dose Reconstruction 

Implementation Guideline (OCASIG-001), which allows dose 

reconstructors to adjust organ 

doses to account for non-uniform 

exposure geometries (NIOSH 

2007). 

Awaiting 

SC&A/Board 

review of updated 

response
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

Although the higher level 

guidance in OCAS-IG-001 already 

permits the dose reconstructors to 

use DCAS-TIB-0010 to adjust the 

doses for organs in the lower torso 

when the circumstances are 

appropriate, NIOSH will add the 

following to Section 6.4 of 

ORAUT-TKBS-0007-6 as 

additional guidance for the dose 

reconstructors. 

An underestimation of 

external dose can occur for 

organs in the lower torso 

when workers spend a 

significant amount of their 

time working with radioactive 

materials in gloveboxes or 

other benchtop work 

environments (referred to as 

just glovebox work after this 

point). At the INL site, 

glovebox work involving 

radioactive materials was 

predominately performed in 

laboratory settings, uranium 

processing areas, some 

settings requiring work in an 

inert atmosphere, certain 

maintenance applications, and 

at sample collection stations. 

In general, DCAS-TIB-0010 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

adjustments to the measured 

and missed external photon 

and neutron doses should be 

considered for cancer organs 

in the lower torso when 

glovebox work is indicated in 

claim documents (e.g. the 

computer assisted telephone 

interview) and when the 

identified places of work or 

work activities would have 

included glovebox work. 

20 ORAUTTKBS-0007-6 O

Issue 20: (5.1.4.1.5) Restating Beta Dose As 

Gamma Dose - It is not claimant favorable to state 

that the entire dose measured in the open window 

is due to the beta dose. 

99

Open window beta dose is 

discussed in OCAS-IG-001. 

Please provide a basis for these 

opinions – where has SC&A found 

data supporting <30 keV photons?

SC&A 

recommends 

closing

21 ORAUTTKBS-0007-6 O

Issue 21: (5.1.4.1.6) Photon Spectrum Split –

NIOSH should provide guidance assigning dose 

values for the 30 keV<E<250 keV and E>250 keV 

regions.

99

Photon energy ranges are based 

upon the predominant 

radionuclides found in the 

workplace. Scenarios, like those 

discussed in the SC&A report 

would be reconstructed on a caseby-case basis. Please provide a 

basis for these statements and for 

the SC&A opinion that a 50/50 

energy range is more appropriate.

SC&A 

recommends 

closing

22 ORAUTTKBS-0007-6 O

Issue 22: (5.1.4.1.7) Immersion Dose - The dose 

recorded on a dosimeter due to a semi-infinite 

cloud irradiation would be approximately half of 

the actual dose received. NIOSH should, 

therefore, consider a weighting factor of 2 for 

immersion dose.

100

NIOSH does not use personnel 

whole-body or extremity 

dosimeter data to estimate internal 

doses. The comment listed in this 

matrix does not appear to coincide 

with the discussion in the SC&A 

Closed
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

review report. This comment may 

be an error because there is no 

mention of semi-infinite cloud 

exposures in the TBD.

23 ORAUTTKBS-0007-6 9

Issue 23: (5.1.4.1.8) High-Risk Jobs 

(Beta/Gamma Exposure) - Site experts interviewed 

by SC&A classified INL as an “acute dose” site, 

with a significant number of facilities, operations, 

experiments, and occurrences providing the 

possibility of personnel receiving dangerous levels 

of radiation. NIOSH did not evaluate 

comprehensively the facility and field data to 

identify and separate out the high-risk or high-dose 

jobs for worker external exposures. This 

information is essential for dose reconstructors to 

fill in the data gap when dose records in a 

claimant’s file are not complete. 

100

Please provide a basis for these 

statements regarding NIOSH 

evaluation of facility and field 

data. The referenced section of the 

SC&A report does not appear to 

relate to the comment provided. 

The report discusses beta dose and 

hot particles. NIOSH would only 

perform dose reconstruction for 

hot particles or unreported skin 

contamination that were 

documented. There is no 

reasonable way to estimate hot 

particle doses without monitoring 

data.

03/12/14 Update: As tasked 

during the 2011 INL Working 

Group meeting, NIOSH has 

conducted additional research on 

INL practices to monitor and 

control skin contamination. The 

results of that investigation have 

been provided to the INL working 

group in a white paper.

SC&A 

recommends that 

this finding remain 

open for further 

discussion.

24 ORAUTTKBS-0007-6 O

Issue 24: (5.1.4.1.9) Extremity Dose - NISOH 

should evaluate the potential for missed extremity 

dose for workers working in facilities where 

highly contaminated equipment, piping, 

instruments, valves, and systems resulted in 

100

NIOSH is currently pursuing 

development of formal project 

(TIB) guidance to address this 

issue. Refer to the submitted 

paper for background information 

SC&A 

recommendation is 

pending a review 

of NIOSH’s 

response to its WG 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

exposures in confined spaces to hands. on this issue.

INL assigned extremity dosimetry 

when needed. For other workers, 

NIOSH will address this on a caseby-case basis – we routinely use 

multiplication factors to account 

for geometry differences for 

cancer on extremities when the EE 

was a “hands-on” worker.

03/12/14 Update: As tasked during 

the 2011 INL Working Group 

meeting, NIOSH has conducted a 

review of INL/ANL-W claims 

with extremity cancers. The 

results of the review have been 

provided to the INL working 

group.

action item.

25 ORAUTTKBS-0007-6 O

Issue 25: (5.1.4.1.10) Discrepancies between PIC 

and Film Reading – NIOSH should compare PIC 

versus film badge data (i.e., shallow and deep), 

and ensure that all the dose has been captured by 

the film badge. It is important to note that some 

PICs were worn for only the length of the job, so 

the discrepancy between readings of the twodosimeter systems cannot be explained by drifting. 

Expanded: Many difficulties in comparing PIC 

readings and film results make agreement within a 

factor of two the best that can be expected.

100

The PIC is not a legal record and 

is a lower-preference for 

reconstructing dose. The PIC 

typically over-responded to site 

photon energies and was sensitive 

to shock. They are designed for 

use in the field to get a real-time 

exposure reading until the 

dosimeter could be read at a later 

time.

Closed

26 ORAUTTKBS-0007-6 O

Minimum Detection Limit – NIOSH should reevaluate the approach in determining the MDL of 

the dosimetry system by taking into account the 

101

This observation is similar to 

finding 3 listed below (Comment 

27). The response to the finding 

SC&A

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

system uncertainties. 

Expanded: The selection of 10 mrem as the MDL 

[minimum detection limit] for high energy gamma 

is questionable. Even for modern densitometers 

and film, it is a challenge to achieve this level, as a 

single density “click” can correspond to greater 

than 10 mrem for high-energy gamma radiation; 

this is not a problem, however, for intermediate 

and low-energy x-rays. Rather, one click of the 

densitometry system may correspond to 15 or 20 

mrem for 660 keV or 1.2 MeV gammas, for 

example. If the claim is made that 10 mrem is a 

valid choice for the MDL, then supporting 

materials should be provided, such as film dose-todensity curves and densitometer calibration data. 

Other sites (e.g., Savannah River Site - SRS) have 

adopted 40 mrem as the high-energy gamma MDL 

for early film. 

also satisfies this observation.

27 ORAUTTKBS-0007-6 3

Issue 27: (5.1.4.1.12) Minimum Reporting Level 

(Beta/Gamma) - NIOSH does not provide 

adequate information supporting the use of chosen 

detection threshold levels to represent the MRL 

values for gamma film badges and TLDs. The use 

of MRL/2 as the missed external dose for dose 

reconstruction per OCAS-IG-001 is not claimant 

favorable for claims where the probability of 

causation value is close to 50%. In addition, 

NIOSH should re-evaluate the MRL values used 

and provide more supportable default values. 

103

The MRLs used in the INL TBD 

are based on peer-reviewed and 

published, scientific documents as 

referenced in table 6-15 (see 

footnote b in Rev. 2 of the TBD). 

Comments on OCAS-IG-001 are 

usually more programmatic in 

nature and not part of a specific 

site. In this case, the reviewer’s 

comment is not accurate. MRL/2 

is assigned a lognormal 

distribution as required in OCASIG-001 and discussion of 

uncertainty may be found therein. 

SC&A 

recommends that 

this issue remain 

open.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

Additionally, when the PoC is

between 45 and 52%, the IREP 

sample size increases from 2,000 

to 10,000, the random seed (which 

is normally 99) is selected by 

chance, and IREP is run 30 times 

at the 99th percentile versus the 

50th percentile. These methods 

provide a more claimant favorable 

dose reconstruction and ensure 

that the PoC is not underestimated.

28 ORAUTTKBS-0007-6 3

Issue 28: (5.1.4.2.1) Minimum Reporting Level 

(Neutron) - NIOSH’s approach for determining the 

MRL values for NTA emulsion film is not 

thorough or supported. For example, NIOSH uses 

10 neutron readings in one data sheet from March 

1958 to determine the MRL values for the period 

between 1951 and 1957, and 6 neutron readings to 

represent all neutron measurements between 1959 

and 1976. Furthermore, the use of MRL/2 as the 

missed external dose for dose reconstruction per 

OCAS-IG-001 is not claimant favorable for claims 

where the probability of causation value is close to 

50%. In addition, NIOSH’s MRL values of 14 

mrem and 20 mrem appear low and are 

inconsistent with generic values given for NTA 

dosimeters, as well as values cited by other DOE 

facilities with similar neutron source terms and 

detectors. NIOSH should re-evaluate the MRL 

values used and provide more supportable default 

values.

108

Data capture needed to close 

this issue out

Comments on OCAS-IG-001 are 

usually more programmatic in 

nature and not part of a specific 

site. In this case, the reviewer’s 

comment is not accurate. MRL/2 

is assigned a lognormal 

distribution as required in OCASIG-001 and discussion of 

uncertainty may be found therein. 

The MRLs used in the INL TBD 

are based on peer-reviewed and 

published, scientific documents as 

referenced on page 22. The MRL 

of 14 is cited on page 6 of 

Cipperly 1958. Additionally, 

when the PoC is between 45 and 

52%, the IREP sample size 

increases from 2,000 to 10,000, 

the random seed (which is 

normally 99) is selected by 

SC&A is waiting 

for NIOSH white 

paper.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

chance, and IREP is run 30 times 

at the 99th percentile versus the 

50th percentile. These methods 

provide a more claimant favorable 

dose reconstruction and ensure 

that the PoC is not underestimated.

03/12/14 Update: As tasked 

during the 2011 INL Working 

Group meeting, NIOSH is 

revisiting its response about 

detection limits. NIOSH’s 

response to address the NTA film 

dosimeter detection limits will be 

in the form of a white paper. 

Completion of the white paper is 

pending additional data capture at 

the INL.

29 ORAUTTKBS-0007-6 2

Issue 29: (5.1.4.2.2) Failure to Properly Address 

Neutron Exposures - INL had a total of 52 

reactors, most of which were experimental/ 

prototype in design, which typically operated with 

high-power densities and with minimum shielding 

and neutron moderation. It is unjustified to 

presume that there are no missed neutron doses. In 

addition, there are deficiencies associated with 

neutron calibrations. Due to the use of the PoBe 

source for neutron calibration, dosimeters would 

significantly under-measure neutron doses from 

sources with lower-energy spectra. NIOSH should 

re-evaluate the entire approach in the TBD to 

account for potential missed neutron doses. 

109

The inappropriate instructions to 

discount an INEL worker's missed 

neutron doses has been eliminated 

from the Missed Neutron Dose 

Section of the external dosimetry 

TBD. Because it was impossible 

to determine who a worker's 

coworkers were from the redacted 

dosimetry records, the guidance in 

Rev 02 of that TBD was not being 

used to eliminate missed neutron 

doses. However, it should be 

noted that ORAUT-OTIB-0023 is 

still considered an appropriate 

basis for eliminating unreasonably 

SC&A 

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

Expanded: The method presented in the TBD of 

determining who needs to be assigned a missed 

neutron dose is circular: Section 6.5.4 states: “If 

no neutron dose was assigned to the worker or 

coworkers for several months, the dose 

reconstructor should assume that the person was 

not exposed to neutrons.” Clearly this does not 

allow for individual workers having temporary or 

varying assignments. Also, if the program failed 

to correctly identify that they should have been 

monitored, the record will show no assigned 

neutron dose. 

In addition, the TBD makes the assumption that 

high Z materials, such as iron and lead, were never 

used (e.g., for shield penetrations) in place of 

hydrogenous materials, such as water and 

concrete. However, no attempt is made to validate 

or qualify this assumption.

ORAUT-OTIB-0051, Effect of Threshold Energy 

and Angular Response of NTA Film on Missed 

Neutron Dose at the Oak Ridge Y-12 Facility, was 

issued after the 2004 Site Profile and has a bearing 

on neutron dosimetry issues; hence, it should be 

considered in this TBD. 

high missed neutron doses for 

some INEL claims. In addition, 

neutron dosimeters at the INEL 

were only assigned and read when 

there was a potential for exposure.

Given that most of the reported 

neutron dosimeter results were 

reported as zero, the INEL's 

process to determine who had the 

potential to receive neutron 

exposures appears to have been 

appropriate and adequate.

The guidance provided in Rev 03 

of the external TBD now requires 

missed neutron doses to be 

assessed for every worker using the 

reported neutron dosimeter results, 

unless the missed neutron doses are 

unreasonably high per the guidance 

in ORAUT-OTIB-0023.

NIOSH is not clear what SC&A's 

issue is regarding the potential 

under-measurement of neutron 

doses to lower energy neutrons, 

since Rev 00 through Rev 03 of 

the INEL's external dosimetry 

TBD has included facility specific 

adjustments to the reported 

neutron doses to account for the 

dosimeters' poor energy response 

to lower energy neutrons. The 

NTA film corrections for energy 

response in the INEL TBD are 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

comparable to the energy response 

corrections in ORAUT-OTIB0051, which range from 1.0 to 2.2. 

Because the need to apply a 

correction to NTA film results to 

account for angular response is 

still being debated on a complex 

wide level, no angular response 

corrections were added in the 

latest revision of this TBD. Also, 

the assumption of AP geometry 

would negate the need to adjust for 

angular response.

30 ORAUTTKBS-0007-6 2

Issue 30: (5.1.4.2.3) Neutron Calibration 

Deficiencies - Due to the use of the PoBe source 

for neutron calibration, dosimeters would 

significantly under-measure neutron doses from 

sources with lower energy spectra. NIOSH should 

re-evaluate the approach in the TBD to account for 

potential missed neutron doses.

110

Section 6.3.3.2 indicates that the 

recorded dose is 11% high based 

on this calibration.

SC&A 

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

31 ORAUTTKBS-0007-6 8

Issue 31: (5.1.4.2.4) Completeness and Quality of 

INL Neutron Dosimetry and Record Keeping 

Programs - The identification and determination of 

missed neutron dose for workers are heavily 

influenced by this assumption of confidence, but 

SC&A found this premise to be unsupported after 

examining several critical DOE-HQ Tiger Team 

and DNFSB site audit reports. In addition, many 

site experts interviewed by SC&A indicated that 

there were significant deficiencies and 

inconsistencies in radiation work practices 

throughout the operating history of the INL 

facilities. These observations jeopardize the 

validity of the TBD approaches in reconstructing 

missed worker neutron doses. 

110

Please provide the reports of 

“significant deficiencies and 

inconsistencies in radiation work 

practices” and provide how the 

NIOSH-derived missed dose 

calculations are subject to the 

results of the Tiger Team report.

SC&A 

recommends that 

the WG keep this 

issue open pending 

receipt and review 

of the INL-specific 

coworker model.

32 ORAUTTKBS-0007-6 O

Issue 32: (5.1.4.2.5) Uncertainty Estimation for 

Neutron Doses – NIOSH should explain how the 

FNCFs were obtained and provide instruction to 

dose reconstructors on how to apply them.

110

The latest revision to the TBD 

appears to adequately explain the 

FCNFs. The text indicates that 

this is a correction that INEL 

applied to the dosimeter results to 

generate the reported dose (pg.23 

of TBD). Also, several references 

are cited in the TBD text to 

indicate how these FNCFs were 

obtained. The references also

provide additional information on 

the methodology used.

SC&A 

recommends 

closing

33 ORAUTTKBS-0007-6 O

Issue 33: (5.1.4.2.6) Neutron Organ Dose –

NIOSH should provide neutron spectrum 

information and guidance for organ dose 

reconstruction for workers at ZPPR and TREAT.

110

Guidance provided in Section 6.4, 

spectrum data in Table 6-14 of 

Rev 03.

SC&A 

recommends 

closing

34 ORAUTTKBS-0007-6 9 Issue 34: (5.1.4.2.7) High-Risk Jobs (Neutron 

Exposure) - NIOSH did not evaluate 111 Please provide a basis for these statements regarding NIOSH 

SC&A 

recommends that 
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

comprehensively the facility and field data to 

identify and separate out the high-risk or high-dose 

jobs for worker neutron exposures. This 

information is essential for dose reconstructors to 

fill in the data gap when dose records in a 

claimant’s file are not complete.

evaluation of facility and field 

data. The report discusses that 

there were potential higher dose 

neutron activities conducted but no 

details are provided. NIOSH 

would only perform dose 

reconstruction for such activities if 

they were documented. These 

types of reconstructions would be 

done on a case-by-case basis.

03/12/14 Update: As tasked 

during the 2011 INL Working 

Group meeting, NIOSH has

looked at the interviews appearing 

in SC&A’s site profile review and 

elsewhere for relevant anecdotal 

discussions on neutron exposures. 

The results of that review have 

been provided to the INL working 

group in a separate response 

document.

this finding remain 

open for further 

discussion.

35 ORAUTTKBS-0007-6 O

Issue 35: (5.1.4.2.8) Multiplying Factors for 

Missed Neutron Dose – NIOSH should provide 

data to support the two multiplying factors (1.25 

and 2) and the fixed missed neutron dose default 

value of 50 mrem.

Expanded: See ORAUT-OTIB-0051 and Issue 

No. 29.

111

These values are based on 

weighting neutron spectra with 

dose conversion factors to 

determine the fraction of the dose 

below 0.8 MeV as referenced in 

footnote 37 of Revision 02. It 

should also be noted that the 

upper-bound for the factor of 2 ± 

0.3 is being used (i.e., a factor of 

2.3).

In regards to the 50 mrem of 

SC&A 

recommends 

closing
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

neutron dose, the TBD was not 

recommending that the dose 

reconstructors assign 50 mrem of 

unmonitored neutron doses to the 

affected workers. The TBD was 

merely describing an instance 

where unmonitored neutron doses 

were received by INL workers. 

The earlier versions of the external 

TBD neglected to indicate that the 

INL has already assigned 

unmonitored neutron doses for 

those workers based on the area 

dosimeter results, such that the 

dose reconstructors do not need to 

assign unmonitored neutron doses 

to the affected TAN workers. An 

additional clarifying statement was 

since added to Revision 02 of the 

external TBD that still subsists in 

Revision 03.
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

36 

ORAUTTKBS-0007-6 

 

13 Issue 36: (6.3.2.2) Missed Low Energy Beta Dose 

- Section 6.3.2.2 of the TBD discusses the 

100mg/cm2 plastic dosimeter holder and the fact 

that betas of less than 360 keV will not penetrate 

the holder. (It is unclear if this density includes 

the film wrapper.) However, the TBD does not 

discuss allowance for or consideration of the 

possibility of the complete failure to detect these 

betas. 

The general, averaging approach to missed beta is 

questionable. The concern is that beta exposure is 

always assumed to be due to a mix of energies and 

thus the dose component from low energies is 

known and can be corrected. Clearly this is not 

the case, as is stated in the attribution. 

A specific concern is the Rare Gas Processing 

Facility (CPP-604), which harvested Kr-85. This 

nuclide is a pure beta emitter, with an endpoint 

energy of 670 keV. The film badges in use at the 

time were far from ideal for betas and failed to see 

any below 360 keV. NIOSH should determine if 

the maximum modifier recommended for betas of 

2.8 is sufficient for this environment. 

NA

The current revision to the TBD 

(i.e., Rev. 03) appears to address 

these concerns regarding the INEL 

dosimeter responses to low-energy 

betas.

SC&A 

recommends 

closing

37 

ORAUTTKBS-0007-6 

O Issue 37: (6.5.4) Error in Reference - The second 

paragraph of page 41 of the External Dose TBD 

(ORAUT 2007f) references Table 6-16 for IREP 

groups; it should refer to Table 6-14 instead. 

NA 

Corrected in latest TBD rev. Closed
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Issue Resolution Matrix for INL Findings and Key Observations

Comment 

Number TBD Number Finding Number Issue Number and Description SC&A Page No. NIOSH Response Variance/Status

38 

ORAUTTKBS-0007-6 

O Issue 38: Shallow Dose - NIOSH should consider 

making use of ORAUT-OTIB-0017, Technical 

Information Bulletin: Interpretation of Dosimetry 

Data for Assignment of Shallow Dose, where 

appropriate. Additionally, contrary to the OTIB’s 

claim (p. 15) that the assumption of undergarment 

and pants thicknesses of 2 mm each is claimant 

favorable, SC&A believes that measured 

thicknesses are about half that and, hence, the 

OTIB assumptions are not claimant favorable. 

NA 

This is a complex-wide issue and 

not specific to INEL. Closed

Note: O-Observation